Privacy Policy

Last updated: July 5, 2023

System1 takes your privacy very seriously. In connection with the websites, applications and services that we operate, and with respect to our communications and relationship with you, we are committed to data protection, including through compliance with this Privacy Policy. Please read this Privacy Policy carefully, as it contains important information about how and why we collect, store, use, share and otherwise “process” your “Personal Information” (as defined below). It also explains your rights in relation to your Personal Information and information on how to contact us in the event you have questions, or concerns.

For information about the terms upon which we do business, you should also read our Terms of Use.

Table of contents and summary

Key Terms

• Relevant definitions used throughout this Privacy Policy can be found here.

Personal Information we collect about you

• The Personal Information we process about you depends on how you interact with our Services (as defined below) but can include (1) information you provide to us directly, and (2) information we collect through automated data collection or tracking technologies.
• Additionally, third parties may use automated data collection or tracking technologies within our Services to collect information about you.
• More information can be found here.

How and why we use your Personal Information

• We use your Personal Information to understand how you use our Services, to provide our Services to you, maintain records of our interactions with you, to respond to your enquiries, to notify you of changes to our Services, to serve advertisements to you on our Services or for marketing purposes, and to allow you to participate in any interactive features of our Services. We may also use your Personal Information to enforce our legal rights and inform our business strategy. More detailed information can be found here.

Do Not Track

• Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit, including our Services. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Who we share your Personal Information with

• We may share your Personal Information within the System1 Group (as defined below), with our third-party service providers and professional partners, with parties with whom we enter into a corporate transaction, law enforcement agencies, courts or regulatory bodies (to comply with legal obligations) or otherwise with your consent. More information can be found here.

How long your Personal Information will be kept

• We retain your Personal Information for as long as is necessary to achieve the purposes for which it was collected. More information can be found here.

International transfers

• In the event that we transfer your Personal Information internationally, we take steps to ensure that such Personal Information is subject to safeguards in compliance with applicable data protection laws. More information can be found here.

Links to third party sites and content

• Where you access third party sites or content via our Services, it is important that you check the applicable third party’s privacy policy to understand how such third parties will handle your information. More information can be found here.

Supplemental U.S. privacy rights and disclosures

• If you are a consumer located in the United States, you may be entitled to additional information about our use of your Personal Information and you may have certain rights in connection with your Personal Information. More information can be found here.

Supplemental Information for persons in the EEA and UK

• If you are a consumer located in the European Economic Area (EEA) or the United Kingdom (UK), you may be entitled to additional information about our use of your Personal Information and you may have certain rights in connection with our processing of your Personal Information. Details of these rights and how to exercise them are set out here.

Keeping your Personal Information secure

• We have put in place appropriate security measures to keep your Personal Information safe. More information can be found here.

Children Under the Age of 16

• Use of our Services is not intended for and not directed at children under 16 years of age. More information can be found here.

Changes to this Privacy Policy

• This Privacy Policy is updated from time to time. More information can be found here.

How to contact us

• You can contact us online, by post, or email. More information, including our contact details, can be found here.

1. Key terms

Throughout this Privacy Policy, we use the following key terms (defined below):

2. Personal Information we collect about you

The Personal Information we process about you depends on how you interact with our Services. For example:

• Information you provide to us directly:
  • Any information submitted to us when you fill in a form or query field on any of our Services, register to use any of our Services, apply for a job, or subscribe to any of our Services (including your name and email address, or certain demographic information (e.g., your age) as applicable);
  • Information contained in any messages, emails or other correspondence you have with us in the event that you contact us (including your contact details and the content of such communications); and
  • Information contained in and associated with anything you post to our Services.
• Information we collect through automated data collection or tracking technologies

As you use our Services, we may use automated data collection or tracking technologies to collect certain information about your equipment, browsing actions, and usage patterns, including:

• • Details of your use of our Services, including traffic data, referral data, location data, logs, and other communication data and the resources that you use (or information that you retrieve) on our websites and applications and any advertisement offerings or links to third party websites accessed, acquired or considered and related metrics;
  • Information about your computer or other device and internet connection through which you access or interact with our Services, including your IP address, operating system, device type, device ID, and browser type; and
  • Other electronic network activity information — such as browsing history, viewing history, search history and information regarding interactions with our websites or Services (as applicable).

If applicable, we also may use these technologies to collect information about your online activities over time and across third-party websites or other online services which you may use (e.g., behavioral tracking).

The information we collect automatically is generally statistical data, but we may maintain it or associate it with Personal Information that we (i) collect in other ways or (ii) receive from third parties that we work with. We use this information to improve our products and services (including our Services), and to deliver better, more efficient and more personalized services to our users over time.

The tracking technologies we use for this automated data collection may include:

• • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer.
  • Flash Cookies. Certain features of our Services may use local stored objects (or “flash cookies”) to collect and store information about your preferences and navigation to, from, and on our Services.
  • Web Beacons. Portions of our Services may contain small electronic files known as web beacons (sometimes also referred to as clear gifs, pixel tags, and single-pixel gifs) that allow us, for example, to count users who have visited pages, track where they have been referred from, track and report conversions, and to generate other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Depending on the location from which you access our Services, you may refuse to accept the use of these technologies by activating the appropriate settings on your browser, or (where applicable) by refusing to provide your consent to the use of these technologies when you access our Services. Where you do not consent to the use of such technologies, please note that certain parts of our Services may no longer be available or may not function as intended.

• Third party use of cookies and other tracking technologies
  • Some content or applications, including advertisements, available through our Services are served or provided by third parties, including advertisers, ad networks and ad servers, content providers, and application providers. These third parties may also use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information these third parties collect may be associated or matched with certain of your Personal Information which they have already collected, or they may collect information in the future, including Personal Information about your online activities over time and across different websites and other online services. They may also use this information to provide you with interest-based (e.g., behavioral or retargeted) advertising or other targeted content.
  • We do not control these third parties’ tracking technologies or how they may be used, during your session or over time. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
    • Some of our Services incorporate Google Analytics Advertising Features, including remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform integrations, and Google Analytics Demographic and Interest Reporting. For information about Google Analytics and currently available opt-outs, please click here.
    • Some of our Services may include advertisements or tracking technologies from Microsoft Bing. To learn more about information collected by Microsoft, please click here. You can opt-out of Microsoft’s personalized advertising services by following the instructions found here.
    • Some of our Services may include advertisements or tracking technologies from Yahoo!. To learn more about information collected by Yahoo!, please click here. You can opt-out of Yahoo!’s personalized advertising services by following the instructions found here.
    • You can also generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (DAA) by visiting the opt-out pages on the NAI website and the DAA website, respectively.

3. How and why we use your Personal Information

We use your Personal Information only for the purposes described in this Privacy Policy (or such other purposes which are compatible with the purposes described in this Privacy Policy). If you do not provide your Personal Information to us, or if we are otherwise prevented from processing your Personal Information, it may delay or prevent us from providing certain elements of our Services to you.

In certain locations (including the EEA and the UK) we are required to have a lawful basis for the collection and processing of such Personal Information. The table below sets out the purposes for which we use your Personal Information and the lawful bases upon which we rely. Where we rely upon our (or a third party’s) legitimate interests, we have assessed that such interests are not overridden by your own rights and interests in your Personal Information.

4. Do Not Track

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit, including our Services. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

5. Who we share your Personal Information with

As necessary for the purposes described above, we may share your Personal Information with:

• members of the System1 Group;
• third party IT vendors (e.g. hosting, cloud services, networking, cybersecurity platforms, telecom providers, managed services providers, customer service platforms, technical support service providers and payment processors);
• third party media, advertising and marketing vendors and monetization partners;
• data analytics providers, social media networks, native advertising networks, programmatic advertising platforms, search engines, monetization partners, syndication and distribution partners, customer engagement services, push notification providers (to provide services that include, but are not limited to, product recommendations, delivering marketing messages including advertisements, and sending you relevant offers);
• partners with whom we work to improve our Services and/or business processes;
• third parties in connection with whom we have received your express consent to share your Personal Information;
• our external auditors, professional advisors, law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and
• other parties that have or may acquire control or ownership of some or all of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your information will be bound by confidentiality obligations.

Additionally, we may disclose aggregated and deidentified information that does not identify any individual.

6. Links to third party sites and content

Our Services may include links to other sites or content operated by third parties. We do not exercise control over third party sites, services or content, and we are not responsible for the privacy practices of any such third parties. Once you leave our Services via a link or by clicking on an advertisement, it is important that you check the applicable privacy policy of the third party’s site or service. The fact that we link to a website or display a banner ad or other type of advertisement is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices.

7. How long your Personal Information will be kept

We retain your Personal Information for a period that is reasonably necessary in order that we can achieve the purposes for which the Personal Information was collected, including to provide you with the Services requested and to support our business purposes as described above in the section and table column titled “What We Use Your Personal Information For” and as described below in the section titled “Business or Commercial Purposes for the Collection and Processing of Personal Information“. As a result, different retention periods apply to different types of information.

Following the end of the relevant retention period, we will delete or anonymise your Personal Information. Personal Information may be kept for longer periods to the extent necessary to comply with a legal or regulatory requirement to which we are subject, or in connection with any legal disputes or claims. Even if you request a deletion, we may be required to maintain your information for as long as necessary to comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us); to exercise, establish or defend legal claims; and/or to protect against fraudulent or abusive activity on our Services.

8. International transfers

Our Services are hosted primarily in the U.S. If you are accessing our Services from outside of the U.S., please be aware that Personal Information collected through our Services may be transferred to, stored in or otherwise processed in the U.S. (or such other jurisdictions where we have engaged a third party to provide services). The laws of such jurisdictions may be different from those of your country of residence, and in some cases, may not be as protective.

In the event that we transfer your Personal Information, we take steps to ensure your Personal Information is safeguarded in compliance with applicable data protection laws. In connection with Personal Information originating in the UK or the EEA, such safeguards may include our execution of the Standard Contractual Clauses and, where applicable, the UK International Data Transfer Addendum, with the recipient of such Personal Information. System1 and the System1 Group are required to protect Personal Information that they process from the UK or the EEA in accordance with applicable European data protection laws. If you require more information about our international data transfers and the applicable safeguards, please contact us using the details provided in the “How to contact us” section of this Privacy Policy.

9. Supplemental U.S. state specific privacy rights and disclosures

This section applies only to Personal Information collected about consumers residing in the United States. Depending on the state in which you reside and the way in which you interact with us and our Services, you may be entitled to additional disclosures regarding the Personal Information we collect about you. You also may have certain rights regarding that Personal Information.

Personal Information we have collected

In the preceding 12 months, we may have collected or processed the following categories of Personal Information:

• Identifiers — such as name, email address, device type, web browser, operating system or other similar identifiers;
• Unique online identifiers — such as IP address, device IDs derived from device type, or other similar identifiers;
• Certain commercial information — such as the Services, advertisement offerings or links to third party websites accessed, acquired or considered and related metrics;
• Other electronic network activity information — such as browsing history, search history and information regarding interactions with our websites or our Services;
• Location information – geo-location information about where you are accessing our Services (e.g., if you access our Services on your mobile or tablet device we may collect information about your device’s precise location to the extent feasible);
• Online viewing activities and habits (e.g., videos viewed, pages viewed);
• Consumer’s precise geolocation (where applicable);
• Certain demographic data (e.g., gender, age, etc., where applicable); and

Business or commercial purposes for the collection and processing of Personal Information

We may have collected these categories of Personal Information for the following purposes (and including for any purposes otherwise described in this Privacy Policy):

• Operate, manage, and maintain our businesses and infrastructure;
• Provide, develop, improve, repair, and maintain our products and Services;
• Performing services on behalf of our various businesses, such as user retention, providing content recommendations and/or processing information;
• Fraud and crime prevention;
• Debugging errors in systems;
• Marketing and advertising;
• Perform accounting, audit, and other internal functions, such as internal investigations;
• Comply with law, legal process, and internal policies;
• Internal research, analytics and development — e.g., user-preference analytics;
• Developing, maintaining, provisioning or upgrading networks, products, services, or devices;
• Payment processing and verification (where applicable); and
• Customer support and inquiries.

We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about individuals.

Sources of Personal Information

We collect Personal Information:

• Directly from you, including technical and usage information when you use our Services;
• From linked sites, such as social media sites, and other third-party platforms;
• From our various affiliated entities;
• From our joint-ventures and promotional and strategic partners;
• From information suppliers;
• From distributors, service providers and other vendors; and
• From marketing mailing lists

Retention of Personal Information

Our retention practices are described above under the section titled “How long your Personal Information will be kept.”

Categories of Personal Information we disclose

As described above under the section titled “Who we share your Personal Information with“, we share your Personal Information with companies such as third-party media and marketing vendors, data analytics providers, social media networks, native advertising networks, programmatic advertising platforms, customer engagement services, push notification providers, and others to provide services that include, but are not limited to, product recommendations, delivering marketing messages including advertisements, and sending you relevant offers.

Such disclosure of Personal Information may be considered a “sale” or “sharing” of information under applicable state law. For example, under California law, a “sale” is the disclosure of Personal Information to a third party for monetary consideration or anything of value, and a “share” is the disclosure of Personal Information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

The categories of Personal Information that we disclose in this manner are as follows:

• Identifiers — such as email address, device type, web browser, operating system or other similar identifiers;
• Unique and online identifiers — such as IP address, device IDs derived from device type, or other similar identifiers;
• Certain commercial information — such as Services accessed, acquired or considered;
• Internet or other electronic network activity information — such as browsing history, search history and information regarding interactions with our websites or Services;
• Location information – geo-location information about where you are accessing our Services (e.g., if you access our Services on your mobile or tablet device we may collect information about your device’s precise location to the extent feasible);
• Online viewing activities and habits (e.g., videos viewed, pages viewed); and
• Consumer’s precise geolocation (where applicable).

Some of our processing activities may constitute “targeted advertising” as that term is defined in applicable law.

Your U.S. state privacy rights

Depending on the state in which you reside, you may have certain privacy rights regarding your Personal Information, including (if applicable):

• The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purposes for collecting, selling or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we collected about you;
• The right to confirm whether or not we are processing your Personal Information;
• The right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
• The right to delete Personal Information that we collected from and/or about you, subject to certain exceptions;
• The right to correct inaccurate Personal Information that we maintain about you, subject to certain exceptions;
• The right, if applicable, to opt out of (1) the sale or sharing of your Personal Information; (2) targeted advertising; and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• If we use or disclose sensitive Personal Information for purposes other than those allowed by applicable law, the right to limit our use or disclosure;
• If we are required by applicable law to obtain your consent to process sensitive Personal Information, the right to withdraw your consent; and
• The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

You can contact us with your request through one of the contact methods described under the section titled “How to contact us“. We may ask you to provide information that will enable us to verify your identity in order to comply with your request to exercise your privacy rights. Consumers in some states may also authorize an agent to make requests on their behalf. In particular, when a California consumer authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from the consumer to submit the request, or we may require the consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request on their behalf. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request in accordance with the requirements of applicable law.

You may have the right to appeal our decisions made with respect to on your request. To appeal our decision on your request, you may contact us through one of the contact methods described under the section titled “How to contact us“. Please enclose a copy of, or otherwise specifically reference, our decision on your request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

You may also request information about our practices related to the disclosure of your Personal Information by members of System1 Group to certain third parties for their direct marketing purposes. You may be able to opt out of our sharing of your Personal Information with unaffiliated third parties for the third parties’ direct marketing purposes in certain circumstances. You can contact us with your request through one of the contact methods described under the section titled “How to contact us“.

Your right to opt out of the sale or sharing of Personal Information

You may have the right to opt out of the sale of your Personal Information by contacting us through one of the contact methods described under the section titled “How to contact us” or by clicking on the link “Do Not Sell or Share My Personal Information” at the bottom of the page.

However, please note that your use of our website may still be tracked by us and our vendors or partners to perform functions that are necessary for our businesses, such as hosting our website, ensuring there is no fraud (click-fraud, fraudulent or bot traffic), etc. These entities are contractually obligated to keep this information confidential, and will not use it for any purpose other than for the services they provide to our businesses.

10. Supplemental Information for persons in the EEA and UK

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), you may have the following rights with respect to the Personal Information we process about you. Please note that these rights are not necessarily absolute (and certain qualifications may apply). If you have questions related to these rights and their applicability to you, you may contact us.

If you would like to exercise any of the rights set forth above, please:

• Email us—see below: “How to contact us“; and
• provide enough information to allow us to verify your identity (this may include providing your name or, where relevant / applicable, a customer account number (for example), and any additional identity information we may reasonably request from you);
• let us know what right you want to exercise and the Personal Information to which your request relates.

For the purposes of EEA and UK data protection law:

• System1 OpCo, LLC is the data controller and can be contacted using any of the means set out in the “How to contact us” section below.
• EEA: VeraSafe has been appointed as System1 OpCo, LLC’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in connection with data protection matters, in addition to or instead of using the information provided in the “How to contact us” section below. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe Netherlands BV

Keizersgracht 555 1017 DR Amsterdam

Netherlands

• UK: VeraSafe has been appointed as System1 OpCo, LLC’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom, VeraSafe can be contacted in connection with data protection matters, in addition to or instead of using the information provided in the “How to contact us” section below. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +44 (20) 4532 2003.

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.

37 Albert Embankment

London SE1 7TL

United Kingdom

11. Keeping your Personal Information secure

We have appropriate security measures to prevent Personal Information from being accidentally accessed unlawfully. We limit access to your Personal Information to those who have a genuine business need to access and are subject to a duty of confidentiality. Depending on the nature of the risks presented by the proposed processing of your personal data, we will have in place the following appropriate security measures:

• Organizational measures (including, but not limited to, staff training and policy development);
• Technical measures (including, but not limited to, physical protection of data, pseudonymization and encryption); and
• Securing ongoing availability, integrity, and accessibility (including, but not limited to, ensuring appropriate back-ups of personal data are held).

We also have procedures to deal with any suspected or confirmed data security breach. We will notify you and any applicable regulator of a data security breach when and where we are legally required to do so.

12. Children Under the Age of 16

Use of our Services is not intended for and not directed at children under 16 years of age. We do not knowingly collect, sell, or share Personal Information from children under 16 and do not knowingly target our Services to children under the age of 16. Persons under 16 years of age may not use or provide any Personal Information through our Services. If we learn we have collected or received Personal Information from a child under the age of 16, we will delete that Personal Information in accordance with applicable law. If you believe we might have any information from or about a child under the age of 16, please contact us.

13. Changes to this Privacy Policy

This Privacy Policy was last updated on July 5, 2023.

It is our policy to post any changes we make to our Privacy Policy on this page. You are responsible for periodically visiting this Privacy Policy to check for any changes. If we make material changes to how we treat our users’ Personal Information, we will let you know through a notice available in connection with your use of our Services after implementing such changes (you are responsible for ensuring we have an up-to-date active and deliverable email address for you, where relevant).

14. How to contact us

Please contact us if you have any questions about this Privacy Policy or the information we may hold about you, to exercise a right under applicable data protection laws, to make a complaint or make inquiries.

Our contact details are shown below: